Contact us
Visit CPRE.org
Donate
Water In Kent; Our View!
SOUTHERN WATER
APPLICATION FOR DROUGHT PERMIT BEWL WATER RESERVOIR
CPRE STATEMENT.
1. The Kent Branch (“Protect Kent”) of the Campaign to Protect Rural England exists to promote the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources in town and country. Our comments on the Drought Permit application relate to the implications for the sustainable management of Kent’s water resources.
2. Southern Water has made its case to the Environment Agency for a Drought Permit on the grounds that storage in Bewl Water reservoir is now substantially lower than normal for the time of year (approx 41%) and groundwater reserves, which provide 70% of the supplies to Kent’s households are also severely depleted. Bewl Water constitutes the storage element of the Medway Scheme (Licence No 02/114) by which the Company is authorised to pump up to 250 Ml/d to the reservoir from the Medway at Yalding and up to 136 Ml/d into supply from the river at Springfield near Maidstone; subject to a Minimum Residual Flow (MRF) of 275 Ml/d as measured at Teston Weir. This is essentially a “hands – off” flow to protect the biological and chemical quality of the river and the interests of other lawful abstractions. The Medway flow is already below the MRF and SW are seeking authorisation to continue pumping to storage by reference to a reduced rate of 100 Ml/d. The permit, ifgranted will expire on 31st March.
3. CPRE recognises the urgent need for the Company to improve the reservoir stock, but it should be noted that the permit is being sought under conditions similar to those which obtained in 2005/06 when we made known our concerns with respect to the lack of investment by the industry in new sources of supply on a scale sufficient to meet the anticipated increase in demand arising from climate change and population growth in the SE. Kent has been officially identified us “Water Scarce” and the situation faced by SW should not therefore come as a surprise. Unfortunately Ofwat, in line with its objective of minimising increases in charges to customers, has actively discouraged water companies from making investment in large scale water resource development schemes. We now see the effect of this short term thinking in the threatened failure of Bewl Water which has a current rated output lower than when first commissioned more than 40 years ago. And with the additions of supply areas in Ashford and Hastings, it is expected to serve a significantly larger population, making it even more drought-sensitive.
4. Our conclusion is that the Bewl/Medway system can no longer guarantee security of supply without frequent recourse to emergency measures such as those defined in the Permit, and which should in practice only be invoked under exceptionally severe drought conditions. If the Permit is granted, it will have been the second occasion in approx 6 years when SW have been obliged to resort to such measures; and this tells us something about the Company’s capacity to deal with conditions which, although severe, cannot be rated as extreme events.
5. Defra’s new water white paper “Water for Life”, released in December last year, sets out Governments’ vision of a new coherent strategy for the management of water resources; aiming at a draft Bill later this year. It recognises that resources are already under pressure and that the supply deficit will continue to increase, threatening the environmental quality of our rivers and wetlands. The paper goes so far as to propose a pause on housing development for any given area until a water supply (and sewerage) infrastructure of adequate capacity is put in place. Paragraphs 6.45 – 6.49 of the paper also draw on the findings of a review of Ofwat’s role in determining whether their regulatory approach was “fit for purpose”. A number of areas for improvement were identified, including (Para 6.47), incentivising a more sustainable approach to the use of water resources; looking to keeping bills low in the short term but having a longer perspective on the impact that its decisions are likely to have on affordability and future resilience. It was also acknowledged (6.49) that Government could provide a stronger steer to Ofwat on how it should interpret its sustainable duty. This is to be welcomed as a move toward more balanced assessments of the economic, social and environmental components of resource management strategies.
6. CPRE, having consistently campaigned for the identification of new sources of supply (e.g. recycled waste water and bulk transfers from other regions with more abundant resources), looks to the Environment Agency to treat this application as another reality check and an opportunity to send the message back to Government that if we fail to invest in a more robust and flexible water resource development strategy, we will have to be resigned to the prospect of drought restrictions becoming a permanent feature of water supply management in Kent.
- A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
- There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
- There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.
The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:
- There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
- A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
- Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
- Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.
Concerns about the rush to submit the plan
The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.
As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.
Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.
Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.
The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.
Further information
